Section 23 (o)
19.47. Despite the recommendations of the Coombs Task Force, Parliament has not repealed section 23 (o). That section
exempts from taxation income derived from the working of a mining property by the taxpayer during a relevant year of
income principally for the purpose of obtaining gold, or gold and copper—in the latter case where the value of the
gold obtained from the property in that period is not less than two-fifths of its output other than the value of
pyrites. A taxation concession for gold has been in the legislation since 1924. The section of the Act in its amended
form is the result of the amendment effected in 1952. There is no deduction under Division 10 for exploration and
prospecting or for capital expenditure in relation to mining for gold, as these deductions are allowable only from
assessable income and income derived from gold mining is exempt. Whether an incentive should be given in this or some
other way for the mining of gold is not a decision for this Committee to make. If section 23 (o) is to remain in the
Act, however, consideration should be given to its amendment to overcome the problems referred to in Appendix A and
which, broadly speaking, arise by virtue of the restriction of the ambit of the section to ore taken from a mining
lease held by the taxpayer, as distinct from that taken from another source in which the taxpayer has an interest. It
should be noted that Parliament has considered that incentives should be provided for the production of gold in that,
under certain
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conditions, a subsidy is payable to the producer of gold bullion under the Gold-Mining
Industry Assistance Act 1954–1972.